The Zumbrun Law Firm v. California Legislature

Plaintiff, The Zumbrun Law Firm, brought this action as a taxpayer against defendants California Legislature, its Committees on Rules and others, seeking declaratory and injunctive relief, claiming that a contract for the Capitol Park Safety and Security Improvements Project (Capitol Project), entered into by the Committees on Rules of the Legislature to improve security measures at the Capitol by controlling access to the State Capitol building and grounds, violated the separation of powers doctrine of the state Constitution and unlawfully restricted competitive bidding under the State Contract Act (Pub. Contract Code, § 10100 et seq.) by requiring an all-union workforce. Plaintiff also sought, but was denied in part, records relating to the contract under the Legislative Open Records Act (LORA; Gov. Code, § 9070 et seq.).

The trial court concluded the contract did not violate the separation of powers or the State Contract Act. It also concluded that the denial of discovery of certain records did not violate LORA. We agree.

The contract did not violate the separation of powers doctrine of article HI, section 3 of the Constitution because under article IV, section 7 of…